[ SHOUL D Y OU OR S H OUL DN ’ T YO U ] The Copyright Clearance Center Blanket License: Is it Right for Your Library? 1 [ ABOUT US] T H E VA NTAGE P O IN T S E R IE S F R O M EBSCO IN FORMATION SERVICES ® addresses important issues in the serials information arena and provides unique, knowledgeable perspectives on these issues. As a leading information services provider, we, at EBSCO, believe the perspectives provided can clarify ways in which these issues might affect your library or organization. This Vantage Point issue contains two presentations made by library professionals at the EBSCO Executive Seminar, held January 13, 2008, in Philadelphia, Pennsylvania, during the 2008 Midwinter Meeting of the American Library Association. For research library directors, the EBSCO Executive Seminar event is held annually and focuses on issues shaping the future of research libraries. [ CONTENTS] Pennsylvania State University: Our Evaluation of the Copyright Clearance Center Blanket License a presentation by NAN C Y L. E AT O N , DE AN O F UN IV E R S IT Y L IBRARIES AN D SCH OL ARLY COMMUN ICATION P ENNSY LVA NI A S TAT E UN IV E R S IT Y Meet Us at the Margins: Reasons to Consider the Copyright Clearance Center Annual Copyright License a presentation by F R E D M . H E AT H, V ICE P R O V O S T AN D DI RECTOR UN I VE R SI T Y O F T E X AS AT AUS T IN L IB R ARIES 1 (This page intentionally blank.) Pennsylvania State University: Our Evaluation of the Copyright Clearance Center Blanket License NANCY L. EATON, Dean of University Libraries and Scholarly Communication, Pennsylvania State University I want to stress that this presentation is about the process by which Pennsylvania State (Penn State) University evaluated the Copyright Clearance Center (CCC) Blanket License — not the particular conclusions that we came to, but how we proceeded and the various perspectives of those working in a very large research institution. We actually addressed this issue in May 2006, when the CCC executives visited Penn State to present their new product, the “Annual Academic Copyright License.” At the time, the CCC was visiting a number of institutions seeking charter members who could partner with them in the further development and rollout of their product. So, we were probably within the first 12 institutions that they talked to before it was actually rolled out as a final product. The academic product was modeled on one that the CCC had developed for the corporate sector that, according to CCC executives, had been very successful in streamlining copyright clearance for corporations. The CCC was marketing the license as a way of streamlining approvals for copyright and simplifying workflow for colleges and universities. Those were the two things they stressed the most. They were using language, however, in their verbal presentations, like “one-stop shopping,” and the title itself, “a blanket license,” certainly implies fairly broad coverage. The issue for us was to determine to what degree it really provided encompassing coverage in a way that would be helpful to us. Thirteen members were asked to attend the presentation and, to my amazement, all of them did. This was significant, because it was important to us to have all of the players at the table to hear the same thing — myself, of course, and the director of the Penn State Bookstore, who does the course packs for the University; the senior coordinator for copyright clearance (which is actually a separate part of the University that does copyright clearance for faculty when it is outside the Library’s purview); four people from the library: the electronic resources and copyright librarian, the coordinator for interlibrary loan, the supervisor for electronic reserves, and the head of access services. There was also my director of administrative services who handles the financial planning for the Library. In addition, there was the director of the Penn State University Press; the senior director for teaching and learning with technology, who is the person in University computing that oversees the course management system for the University; the assistant vice president for research and technology transfer, who is also the director of intellectual property for the University; and the associate vice president for outreach and extension, who runs our international online world campus. And finally, our legal counsel. All of us attended the CCC presentation together so that we would hear the same information and could then evaluate it collectively. Sanford (Sandy) Thatcher, director of the Penn State University Press, who by then was reporting to me, was a member of the CCC board of directors which made it particularly interesting. He believed very much in this product, in that it would help institutions simplify copyright clearance, so he asked us to at least consider it. Rather than Sandy going around the University talking to different people and each hearing different things, he and I agreed that I would call together a variety of individuals from across the University who would either be logical users of the license or who would have administrative or legal opinions about its appropriateness for the University. 3 About Pennsylvania State University Before continuing, I will provide a brief description of Pennsylvania State University and the University libraries, as we did for the CCC executives who visited us, since that was key to our evaluation of the CCC Blanket License. We’re probably as complicated as any institution can be in higher education. Penn State is legally one University, even though we have 24 campuses. We are one University, with one president, one provost, one board of trustees, one library dean, and one academic computing chief information officer. We have 37 libraries among 24 campuses across the entire Commonwealth of Pennsylvania, including one here in Philadelphia. The composition of our faculty and students is almost 7,000 faculty and 84,000 students. We are a very decentralized, very distributed University and probably the only one like this that is legally an institution. While the University libraries all report to me, as does the Penn State University Press, some of them have a great deal of autonomy, such as law and medicine. Similarly, while the University supports the ANGEL® course management system, it is not the only one used. The law and medical schools, for instance, use different course management systems. Faculty members have a great deal of autonomy in how they teach. Even use of the CCC is a shared responsibility between the University libraries and the senior coordinator for copyright clearance. The distributed, decentralized nature of the University was a critical factor in the evaluation of the CCC Blanket License, as Penn State is extremely complex. The CCC representatives were quite surprised by this level of complexity. After the CCC presentation, the Penn State participants remained together to critique what we had heard. Our analysis was as follows: Analysis Coverage: In spite of the implication that this would provide assurances to faculty that going through the CCC site would ensure compliance with copyright, coverage is limited. At that time, in May 2006, it covered only 200 publishers. It covers books, journals, newspapers, trade publications and text books, but it does not include media, interlibrary loan or document delivery transactions. It is for academic use only, including course packs, classroom handouts, library reserves and electronic course content, but it does not include non-educational uses such as promotional or advertising uses or use in publications. It is 4 definitely not an all-inclusive license, in spite of it being called a “blanket license.” This would not be easy for faculty or staff to understand, as they are led to believe by the promotional material, or could easily interpret, that if they go through the CCC license, they are complying with copyright. Fair Use and Licensed Content: Under fair use, we already have rights to use much of this material for academic purposes, and much is already licensed by the Libraries directly from publishers. We spend more than $7 million per year on licensed electronic content, both books and journals. If faculty were to use the CCC site directly without anyone filtering these requests, we would pay twice as much (or more, depending on the number of requests) for many of these materials. At present, the Libraries take responsibility for e-reserve and interlibrary loan requests to search and eliminate requests for materials that are already licensed or fall under fair use. We encourage faculty to come through us for materials in their online courses, as we have designed library access into the course management system, including direct links to the electronic resources. For the remainder of requests, under the current system of pay-per-use, our statistics indicate that the CCC denies or indicates that the request is unavailable for almost 50 percent of our requests, which we then pursue ourselves. The license would not provide any additional coverage for this material. Liability: Legal counsel expressed the opinion that we would increase our liability rather than reduce liability, since faculty were likely to believe that more was covered by the license than was actually the case and would be, therefore, more likely to make mistakes in applying copyright law to their teaching and research. Workflow: The CCC argues that the license would save work for the Libraries. Yet, after hearing our concerns, it suggested that the Libraries monitor and review the requests by faculty using the course management system(s) and to direct all such requests through the Libraries’ interlibrary loan operation and our e-reserve operation, which would increase our workload, not reduce it. After discussion, we came to the following conclusions: • The reporting requirements were not acceptable to Penn State. The headcount basis for the establishing costs was not acceptable to Penn State. • Library workloads would, in fact, increase rather than decrease. • Liability could be greater rather than less. • Our complex, decentralized system does not lend itself to a CCC centralized license and one centralized payment by the University. • The mix of materials used by Penn State as a heavily researchoriented University went far beyond the coverage of the CCC license. Pricing: Pricing is per student, based on the University’s Carnegie classification and full-time employee count. This would presumably be very large for Penn State with 84,000 students. On principle, we do not agree to headcount pricing for any product and negotiate for cost based on usage. The CCC literature did list a University System / multisite discount, though we were never provided a dollar quote for such an option. Typically this is consortial pricing, and, legally, we are not a consortium. Reporting: The description of the license included a requirement to report, in one academic term per year, the following: copies of course syllabi, course packs or class handouts; a listing of content used in digital forms by print services and copy shops; and downloads of content posted on course management systems and/or e-reserves. First, our systems do not presently provide such information. Second, on principle, we would not provide such information to an outside party. The staff of the Libraries, the senior coordinator for copyright clearance, and our senior director from information technology services, who runs the course management system, all agreed that this was not desirable. Centralized Payment: The license requires that the University pay centrally, yet Penn State’s decentralized budget system would make that very difficult. It would require somebody (probably the Libraries) to try to prorate usage and bill the various units of the University for their portion of the CCC license. Again, that would add to workload, not decrease it, assuming it could even be done. Conclusions Summary Based on that analysis in 2006, Penn State chose not to continue licensing discussions with the CCC. Also, by the end of that meeting, the CCC executives acknowledged that Penn State was too complicated to be a potential development partner. I am told that the CCC has revised some aspects of the blanket license since that time, though I am not familiar with those changes. But the CCC has never come back to us to ask us to reconsider our licensing decision. It is possible that such a blanket license would benefit smaller, more centralized institutions with more predictable usage from a core set of publishers, or units within a larger university that might benefit from such a license for a particular discipline. Thus, my purpose in presenting our experience is not to condemn the CCC blanket license per se, but rather to suggest the kinds of questions that you should ask as you evaluate the potential benefits of the program. Penn State continues to use the pay-per-use services of the CCC as a useful service. 5 (This page intentionally blank.) Meet Us at the Margins: Reasons to Consider the Copyright Clearance Center Annual Copyright License FRED M. HEATH, Vice Provost and Direc tor, University of Texas at Austin Libraries T he topic that brings us together tonight is not a happy one. In emulation of their colleagues in the music industry, the Association of American Publishers (AAP), their president and their copyright counsel have subjected America’s libraries to a wearying six-year siege of threatened litigation, impeded workflows, protracted contractual negotiations and corporate wrong think. Litigation is not what publishers do best; they have even allowed their litigants to target the very faculty who provide them with the free content that fills their balance sheet. Something must be done to extricate the parties from this contretemps, or higher education and publishing are both at risk. upon the continuing patronage of the research library community. Can we get off this treadmill? Is there not something we can do to mitigate this adversarial relationship between best customers and some of their suppliers? To this point, at my Libraries we have actually done little to operationalize our inclinations to sit down and talk. But it is probably useful to clear the air and explain why I think it a good idea to do so. If tonight’s session will do anything to advance the understanding between the respective parties, then it will have been time well spent. Let me spend a few minutes to retrace the thought process, to review the tenets that undergird this point of view. When analyzing the landscape, I began to believe that perhaps the wisest course of action was to engage AAP through its proxy, the Copyright Clearance Center (CCC), to end some of these inefficiencies, correct some of the workflow absurdities that sap our efficiency and return to our priorities of teaching and learning. So, I informed the executive director of the Association of Research Libraries (ARL), Duane Webster, that I was inclined to sit down with the publishing community and begin discussions about the Annual Copyright License. I was concerned that my colleagues atop the barricades — who saw AAP’s strategy of litigation as a full-scale assault upon fair use — would view negatively the suggestion that large research libraries could negotiate with the publishing community. I recognize that many librarians are wary of blanket licenses. Thoughtful people have spoken articulately of their concerns that colleges will pay for copyright licenses instead of asserting their rights under fair-use doctrine.1 I also believe that AAP counsel, in its allegations against our colleagues, does not represent the views of most of our friends in the publishing industry. For the most part, the great libraries that are represented by the people in this room were built through decades-long relationships between librarians and publishers. Publishers, I believe, recognize the essential partnership between themselves and libraries — a perception especially acute among the many publishers whose balance sheet is totally dependent 7 The Copyright Clearance Center License The Copyright Clearance Center is a tool of the publishing community, managing licenses that permit the reuse of published material. Over the summer of 2007, the CCC announced the availability of an Annual Copyright License for colleges. Previously available to commercial clients, the new license offers a blanket fee-for-use of publisher content instead of requiring colleges to secure rights to content on a case-by-case, transactional basis.2 We read that the foray into the higher education market by the CCC had some vetting at Middlebury College, and we were pleased with that. We understood that the CCC hoped to contract with 10 to 25 universities in the first year, and we felt, reasonably, that we could perhaps be one of them. To be sure, the business plan has given us pause, and if we proceed we will have to see what negotiation room there is when we get to the table. According to CCC officials, the publishing community anticipates a minimum of $1 per student, with an average fee that could run as high as $10 per full-time employee. We don’t accept that pricing structure with an emergent product. As a large research library already buying a huge proportion of the full gamut of offerings of the publishing community, we see ourselves as an entirely different potential client to the CCC than some narrowly niched commercial partner or a small liberal arts institution. We expect that if we enter into negotiations, these will be stern, protracted and, in the end, entirely reasonable with rates at the very lowest end of the spectrum. Strengths of the New Approach We recognize the current annual license comes with limitations. While many publishers, including John Wiley, New York Times and Oxford University Press, are already aboard, other publishers have not yet put their works under license. CCC’s historical relations with the publishing community led one of its officials to suggest that eventually research libraries will meet 80 percent of their needs through the license.3 That data point was entered into our calculations. 8 We anticipate that the annual license may allow us to reduce our transactional costs. Instead of deciding on a case-by-case basis on whether to seek permissions, we will be able to take a “click and go” approach to securing reuse rights. According to initial information, if an article or book is available under the license, then it can be reused for campus teaching and learning purposes for the duration of the license. Our current workflow requires that for each transaction into electronic reserves, we first adjudicate “fair use” eligibility, an act that has a cost, and then where the article fails the test we must individually acquire the rights for the use of copyrighted content. That act also has a cost. Let me be clear. The conceivable transactions that fall outside direct access to our nine million print volumes and tens of millions of licensed articles represent a small proportion of the total number of value-added knowledge transactions we offer our community during the course of a year. Nevertheless, these e-reserves transactions are something we can engineer away; they are costs we can control.4 Publishers are making the wrong assumption about the fiscal resources that are being lost through course management systems (CMS), course packs and electronic reserves. For most of the publishing community the true ten-horned beast of the apocalypse is not the librarian, nor the library. Rather, the beasts are the faculty, and the new tool, the course management system, that faculty employs to promote teaching and learning. This new digital campus tool, one university press director alleges, has laid waste to the textbook and course pack markets that constituted significant revenue streams for beleaguered publishers.5 I believe that she is wrong, and that she is right. What do I mean? Permit me to use my own Libraries as an example. Our collections have grown tremendously over the past 50 years, and as they have grown, they have evolved. From the 1960s until today, the University of Texas (UT) has invested almost three-quarters of a billion dollars in its libraries. Over those decades we have built strong collections. In many instances, we have repurchased electronic backfiles of journals, books and other resources previously purchased in print form from the same publishers, in order that we could make available to our community a vast universe of resources to their desktops, independent of time and place constraints. So, from that perspective, she is wrong because the marketplace has changed. Libraries are only deploying digital assets as allowed under contract. The investment in licensing packages at ARL research universities is such that faculty have access to a mushrooming universe of digital documents with stable uniform resource locators (URLs) that make it increasingly unnecessary to post non-permissioned, non-fair use, or unlicensed materials to the course management system. We paid for much of that material twice in order to have that freedom. She is right because the textbook market is eroding and course management software is the culprit. It is an easy milieu within which faculty can work, and it is rapidly displacing textbooks, traditional printed course packs as well as their digital competitor, library electronic reserves. The director of the bookstore at the University of North Carolina (UNC) recently reported a four-year decline in the number of courses using course packs from 539 packs to 380. Similarly, UNC Libraries recorded a 20 percent decline in the number of classes using e-reserves over a three-year period, with the number of pages viewed dropping 54 percent over a slightly longer interval.6 And in the aftermath of AAP’s tiff with Cornell University and the issuance of guidelines there, a 70 percent decline in e-reserves use has occurred.7 I observed earlier that publishers for now are emulating their corporate counterparts in the music industry, threatening lawsuits in an effort to shore up a deteriorating marketplace. The battle began at the University of California, San Diego, in 2003, when attorneys for the Association of American Publishers (AAP) objected to the Library’s practice of electronic reserves.8 Then, in March 2006, AAP attorneys contacted Cornell University and again threatened litigation unless perceived violations of electronic reserves were corrected. In response, Cornell University issued guidelines in September 2006 on how to place materials on electronic reserve.9 Then in April 2007, Weil, Gotshal & Manges, the attorneys representing the AAP, struck again posting letters to several of our colleagues. With the passage of time since the first assault, the increasingly sophisticated course management systems and faculty practices in using them were the focus of the ire. But according to our colleagues who received these letters, electronic reserves still came in for their share of vitriol. And the tiresome threat of litigation lingers. Publishers are attempting to stay the tide, and by their reactions, librarians may be persuading them it is possible. Is it possible librarians wish to preserve this rapidly obsolescing system? Rather than perpetuate the current practices and prolong the harangue and rhetoric, can’t we move in new directions? I believe that we should recognize that library-administered electronic reserves, like its print course pack counterpart, may be an anachronistic concept. We should consider that teaching and learning could be more cost effectively served if the librarians took on other roles and ceded that “reserve reading” space to the course management systems. I don’t suggest this be done everywhere, but I believe it could be done in large research libraries. As educators, we want a system that saves the faculty member time so more energy can be expended on teaching, not on preparation. It is not in faculty interest to sustain something so inefficient as either the course pack or library e-reserves. If we again use the University of North Carolina as an exemplar for ARL libraries, there was a “steady linear increase” in the number of Blackboard course sections from fewer than 100 in the year 2000, to more than 5,000 in 2006. Faculty posted resources to the content area in more than 93 percent of the cases far more frequently than they used the grade book feature. Not surprisingly, student behavior was to visit the site briefly and download materials for convenient use.10 9 In the information age, faculty expects transparent systems that allow them to teach effectively. For the current system to work, faculty must know what materials can freely be put online and which materials require a royalty fee or pass a fair use assessment before posting. The best system would be one that: • • • • allows the faculty member to freely post materials that pass a simple test. permits the faculty to defer to others the tasks of fair use adjudication or royalty payment on items that do not pass the test. allows students to freely download all materials on the course management site. calms publisher fears about systemic failings that impact their revenue flow. In a moment, I will close with a quick overview of a system I believe could work. But before I do, I want to persuade you of this — a copyright-compliant university course management system will not resolve the marketplace challenges that university-oriented publishing is facing. Significant tributaries to the publishing revenue stream, textbooks and course packs, are drying up. The industry, like libraries, must find some of their answers of their own on the cost side. So far it appears publishers have been reluctant to explore the cost side. A rational, mutually beneficial solution is possible. Some years ago now, I was speaking with Robert Signorelli, an Anheuser Busch executive, and our small talk turned to the relative merits of boutique breweries and their impact on his marketplace, beer. Mr. Signorelli observed that, from his perspective, the larger breweries offered a superior product but that Anheuser Busch had reason to be concerned with the 1 percent or 2 percent of market share such small producers represented. There is a limit to the size of the beer-consuming market, he observed, and the fortunes of his Company have been managed by careful attention to the cost side. Anheuser Busch had already made its cans as thin as the carbonated content would allow, and transportation routes had been fully rationalized. Therefore, his Company would attempt to move into that small niche market of boutique breweries by allowing its regional brewmeisters to develop signature beers of their own creation, offering those to the beer-drinking public. I would suggest to the publishing community that the same situation prevails among research universities. We are dealing 10 with a revenue situation at the margins. Let’s manage costs. Help us improve our workflows by streamlining our interlibrary loan processes, by simplifying the contractual language of licensing, by aggregating our financial transactions with your community and working together, with us, instead of posturing litigation for six long years running. Look internally at your own workflows and measure the drag of publishing in dual formats; do what you can to restore civility to the marketplace. And if we all do that, perhaps we, too, will discover that there is 1 percent or 2 percent of library operating costs that can be directed toward Annual Copyright Licenses or new acquisitions. We enjoy new efficiencies; you enjoy new revenues. Course Management Systems as the Solution It should be rather obvious that I believe the future to lie in course management systems, the bête noire of the publishing industry. By policy it should be possible to restrict downloads from course management systems to stable URLs within the licensed university domain or public domain resources. • If the faculty member can point to the item, it can be linked to the course management system and downloaded at will by students. The item can be (1) licensed material from the library’s resources; (2) an item within the library’s institutional repository; or (3) an item located on the open Web. • If an item cannot be “pointed to,” the faculty member will forward the request to a trained agent of the university who will determine if the item (1) is available from a publisher participating in the Annual CCC Copyright License; (2) is fair use; or (3) requires a royalty transaction with the CCC. In all three cases, the item can subsequently be made digitally available on the CMS. We believe the transaction load is sustainable and can be further reduced over time by working with faculty to select licensed, stable URLs in lieu of those requiring the extra workflow of adjudication. Permit me again to use a library example with which I am familiar. At the University of Texas Libraries, 400 people participate annually in a $40 million effort to advance teaching and learning at the University. Reserve transactions are an important, but relatively insignificant, part of well over a billion information transactions. Visits to UT library Web sites Downloads licensed/public domain resources 1,000,000,000 10,000,000 Library physical visits 3,000,000 Book circulations 1,300,000 Reserves transactions 740,000 All these transactions have calculable costs, but only with one of these do we as managers have an interest in making go away — the 740,000 reserves transactions. Our initial samplings suggest that approximately one-half of the transactions will go away when moved into the electronic course management system, for they already exist within our licensed resources and we can simply point to them. Of the remaining 370,000 we expect a significant number to fall under the umbrella of the Annual Copyright License, which, when fully operational, should satisfy 300,000 of those according to CCC officials. That leaves us with 70,000 items that are going to require some additional attention, or one-half of 1 percent of the total transactions funded by the University of Texas in support of teaching, learning and research. We can subject those to exacting scrutiny. Some of those 70,000 will be found to be fair use; some will be acquired by the University libraries; some will require royalty payments; and some will be replaced by items from the stable URL universe. Over time the number should dwindle to an idiosyncratic few. A campus agent would manage the Annual Copyright License and the transactional copyright permissions building block — perhaps the Copy Center with an assist from the Libraries. This may be one way out of our adversarial imbroglio. In the summer of 2006, at the Association of American University Presses meeting in New Orleans, Sanford Thatcher, director of Penn State University Press, counseled his community to … educate rather than litigate. ... “We need to take more active steps in educating faculty about their own copyright self-interest,” he said. “I think we should go further and take the faculty member out of the dynamic. The Annual Copyright License may offer us all a step in that direction.”11 As a library manager, I have only one primary mission: the advancement of teaching, learning and research. I want no drag or friction to impede our Libraries as we work toward that goal. I want our behavior to be so unassailably transparent that no publisher would have cause to consider pulling any Library I should manage into court as a potential solution to its marketplace woes. But if the propensity to litigate continues, and should my Libraries ever be targeted, I would want the facts so meticulously aligned that my counsel would welcome the case. I want there to be no doubt as to the outcome. Now, let’s sit down with the CCC and determine just what utility this nascent license may have. 11 Footnotes 1Brock Read, “Copyright Center Will Let Colleges Pay Blanket Fees to Reuse Print Material,” Chronicle of Higher Education 29 Jun. 2007. 2Brock Read, “Copyright Center Will Let Colleges Pay Blanket Fees to Reuse Print Material,” Chronicle of Higher Education 29 Jun. 2007. 3Brock Read, “Copyright Center Will Let Colleges Pay Blanket Fees to Reuse Print Material,” Chronicle of Higher Education 29 Jun. 2007. 4Brock Read, “Copyright Center Will Let Colleges Pay Blanket Fees to Reuse Print Material,” Chronicle of Higher Education 29 Jun. 2007. 5Kate Douglas Torrey, “Downloads, Copyright, and the Moral Responsibility of Universities,” Chronicle of Higher Education 15 Jun. 2007. 6Kate Douglas Torrey, “Downloads, Copyright, and the Moral Responsibility of Universities,” Chronicle of Higher Education 15 Jun. 2007. 7Kate Douglas Torrey, “Downloads, Copyright, and the Moral Responsibility of Universities,” Chronicle of Higher Education 15 Jun. 2007. 8Scott Carlson, “Legal Battle Brews Over Availability of Texts on Online Reserve at U. of California Library,” Chronicle of Higher Education 22 Apr. 2005. 9 Jeffrey R. Young, “Cornell U. Creates Guidelines for E-Reserves,” Chronicle of Higher Education 29 Sept. 2006. 10Kate Douglas Torrey, “Downloads, Copyright, and the Moral Responsibility of Universities,” Chronicle of Higher Education 15 Jun. 2007. 11Jennifer Howard, “Navigating the Big Uneasy: Digital angst and opportunities dominate the annual meeting of university presses in New Orleans,” Chronicle of Higher Education 30 Jun. 2006. EBSCO SUBSCRIPTION SERVICES DIVISION HEADQUARTERS – Birmingham, AL USA Allen Powell President (205) 991-6600 Fax (205) 995-1518 Regional Offices UNITED STATES NEW ENGLAND/MID-ATLANTIC Tinton Falls, NJ CT, DC, DE, MA, MD, ME, So. NJ, S.E. 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